Requirements for All Facilities and SPCC Plan Requirements

I Requirements for All Service Facilities

A. A Spill Prevention, Control, and Countermeasure (SPCC) Plan is not required for U.S. Fish and Wildlife Service (Service) facilities with a total oil storage capacity of less than 1,320 gallons; however, these locations are still required to perform the same equipment inspections (see Table 17-2) using the checklists in Exhibit 2. They are also required to perform the same training and spill reporting as a facility with an SPCC Plan. Table 17-1 specifies the elements that apply to these facilities and provides references to standard forms available in the Service’s SPCC Plan template that may be used for documentation.

B. It is important to remember that, regardless of whether or not an SPCC Plan is required, the same tank inspection and maintenance protocols must be followed to avoid tank integrity testing requirements.

Table 17-1 – Requirements for Facilities with Less than 1,320 Gallons Capacity¹

[1] The required elements are found in the SPCC Plan template.

II  SPCC Plan Requirements

(Links are provided throughout the exhibit to intranet sites where detailed information is maintained.)

A. Who should prepare a Spill Prevention, Control, and Countermeasure (SPCC) Plan?

Facilities with oil equipment and a storage capacity of 1,320 gallons or greater must prepare and maintain an SPCC Plan. The Service has prepared an SPCC Plan template (available by clicking here) that should be used to prepare all new SPCC Plans, and may be used when revising an existing, approved SPCC Plan (Exhibit 3 also contains the references to the Service’s SPCC Plan template and a link to download the template). For assistance in determining who should prepare your SPCC Plan, contact your Regional Environmental Compliance Coordinator (RECC).

B. What should be included in an SPCC Plan?

1. Plan elements and cross-reference to 40 CFR 112. A crosswalk between the SPCC provisions of 40 CFR 112 and your SPCC Plan must be included so that the location of each requirement in 40 CFR 112 can be found. If your existing approved SPCC Plan does not include a crosswalk, then you must prepare one and insert it into your Plan. A copy of the crosswalk is available here. Insert the crosswalk after the cover page and before the Table of Contents. It should be the first item within your Plan.

2. State and local oil storage requirements. Your Plan must address and comply with any state or local oil storage requirements. The requirements must be clearly identified in the Table of Contents, and follow the state or local regulations sequence of provisions. Any Plan prepared to state or local requirements may also need a regulatory crosswalk to those requirements in lieu of, or in addition to, the Federal crosswalk. A section at the bottom of the crosswalk is available for state and local SPCC Plan provisions.

3. Service-specific elements of the Plan. Plans must include the following Service-specific elements:

     (a) SPCC inspection schedule and checklists. The Service’s SPCC Plan template includes a facility inspection schedule (see Table 17-2) (the inspection schedule is based on the inspection checklists in the Steel Tank Institute’s Standard SP-001) and all relevant checklists (see Exhibit 2). Facilities that do not have an SPCC Plan that was developed using this template should also use the Table 17-2 inspection schedule and the inspection checklists provided in Exhibit 2.

Table 17-2 – Facility Inspection Schedule

2 40 CFR 112 requires a tank integrity test every 10 years if we fail to conduct the inspections listed in 561 FW 17, Exhibit 1, Table 17-2. If we follow the inspection schedule rigorously, we do not have to conduct the tank integrity test for all STI Category 1 tanks. See 561 FW 17, Exhibit 1, II B.3(c), “Failure to Inspect.”

     (b) Records of inspections. Records of inspections should be signed by the responsible Service employee and retained permanently.

     (c) Failure to inspect. If we fail to inspect our ASTs according to the schedule in Table 17-2, 40 CFR 112(8)(c) specifies tank integrity testing as the only alternative to demonstrate tank integrity, and we may then be required to perform tank testing per Section D, below. (See Footnote 2.)

C. What are the AST tank categories? The Steel Tank Institute (STI) Standard SP001, 6^th Edition, January 2018 or as amended, describes three categories of ASTs.  Each category is defined by having spill control or Continuous Release Detection Mechanism (CRDM) or both.

1. Definitions.

     (a) Continuous Release Detection Mechanism (CRDM). A means of detecting a release of liquid through inherent design. CRDM is passive because it does not require sensors or power to operate. Liquid releases are visually detected by facility operators. The system must be designed in accordance with good engineering practice. Several acceptable and commonly used CRDM systems are:

     ·        Release Prevention Barrier (RPB). A liquid containment barrier that is installed under the AST. Its purpose is to divert leaks toward the perimeter of the AST where they can be easily detected, as well as to prevent liquid from contaminating the environment. RPBs are composed of materials compatible with the liquid stored in the AST and meet appropriate engineering standards. Examples are steel (as in steel double-bottom tanks), concrete, elastomeric liners, or other suitable materials, provided the above criteria are met;

     ·        Double-wall AST or double-bottom AST;

     ·        Elevated AST, with or without release prevention barrier;

     ·        Steel diked AST, open or closed top; and

     ·        Concrete Exterior AST (CE-AST) with an integral secondary containment and interstitial monitoring opening.

     (b) Spill Control. A means of preventing a release of liquid to the environment. Spill control methods include:

     ·        Remote impounding;

     ·        Secondary containment system;

     ·        Secondary containment dike/berm;

     ·        Open top steel diked AST;

     ·        Closed top steel diked AST with overfill prevention;

     ·        Double-wall AST with overfill prevention; and

     ·        CE-AST with overfill prevention.

2. Applicability to Service Facilities. Table 17-3, AST Integrity Testing and Inspection Schedules, describes how integrity testing is applied to each of the three tank categories.

     (a) Most Service installations qualify as STI Category 1 because they have both spill control and CDRM (e.g., are double-walled, elevated, and have over fill protection; some also have concrete shells).

     (b) If a tank does not meet the Category 1 characteristics (e.g., are single-walled without secondary containment or are sitting directly on the ground) then the periodic integrity testing and other requirements in Categories 2 and 3 apply, and cannot be avoided by regular inspections. Important: The monthly inspections required in Table 17-2 must be followed for all STI categories to prevent leaks and equipment failure.

D. What are the AST integrity testing and inspection schedules? If an integrity test is required, STI Standard SP001 describes the periodic tank integrity testing methods for use on ASTs. The following sections describe the requirements for conducting integrity testing.

1. Shop-fabricated ASTs. Table 17-3 summarizes the inspection and integrity testing requirements for shop-fabricated tanks. Requirements depend on whether the tank has spill control methods and/or CRDM (see the definitions in Section C.1. above). The table is intended to address most Service shop-fabricated tanks, but may not be all-inclusive.

Table 17-3 – AST Integrity Testing and Inspection Schedules

2. Field-erected ASTs. STI Standard SP001 requires that field-erected ASTs (meaning they are constructed on site and are generally large tanks) have a periodic integrity test conducted. See your Regional Environmental Compliance Coordinator (RECC) for the SP001 integrity testing schedule.

3. Integrity Testing for All Service ASTs. All Service ASTs that do not meet the Category 1 standards must follow the tank integrity testing schedules listed in STI Standard SP001, Categories 2 and 3, regardless of whether they have spill control and CDRM.

E. Training.

1. The Facility Manager must provide annual training for all personnel using oil equipment.

2. Training videos prepared by the Service are available that address the inspection of ASTs. These videos are intended to train Service personnel about the components of the ASTs they will encounter and follow the inspection checklists step by step. The videos comply with the Americans with Disabilities Act (ADA), Section 508. The videos without captioning are available here and those with captioning are available here.

3. The instructor or a designee must sign records of training of facility personnel and retain them at the facility permanently. A training lesson plan checklist is provided as “SPCC Training Lesson Plan and Log” in Attachment 6 of the SPCC Plan template, and on the Division of Engineering (DEN) website.

F. Amending the SPCC Plan and the 5-Year Plan Review. Existing SPCC Plans must be reviewed every 5 years to ensure that they accurately describe the physical layout of the facility (see section 17.16 of 561 FW 17). If an existing SPCC Plan is current and contains all the elements required by 40 CFR 112 and described in the crosswalk, it is not necessary to convert that Plan to a new one that uses the Service’s SPCC Plan template. Updating to the new format is an option; it is not required.

1. Plan Amendment Statement and Review Log. Whenever changes are made to the facility, including routine maintenance and replacement with equivalent equipment, the Facility Manager must ensure the changes are recorded in the “SPCC Plan Amendment Statement and Review Log” form. A copy of this log is provided in the SPCC Plan template, Page viii.

2. 5-Year Review Log. Within 90 days before each 5-year anniversary of the SPCC Plan preparation date, the Facility Manager must perform a complete review of the Plan. If the Facility Manager determines the Plan is current and it accurately reflects the oil equipment as well as all other buildings and infrastructure (such as roads, fences, gates, etc.), then they complete the 5-Year Review and Evaluation of SPCC Plan Review form and insert it into the SPCC Plan. A copy of the “5-Year Review and Evaluation of SPCC Plan Review” form is provided in the SPCC Plan template, Page ix.